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Adv. Training Currency Transaction Reporting

Advanced BSA/AML Training
by

BHCR Compliance

on 23 March 2015

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Transcript of Adv. Training Currency Transaction Reporting


Title 31 Overview
How BSA/AML Effects Casinos in the US:
Requires reporting certain currency transactions to ASSIST government agencies in UNCOVERING MONEY LAUNDERING ACTIVITIES and OTHER FINANCIAL CRIMES
Terms/Concepts
Cash In/Out Transactions
Over $3,000 Transaction Forms
Monetary Instrument Log (MIL)
Multiple Transaction Log (MTL)
BSA/AML History
Bank Secrecy Act (BSA) of 1970
Established requirements for record keeping and reporting by private individuals, banks, and other financial institutions

Objective
Identify the source, volume, and movement of currency and other monetary instruments
Currency Transaction Reporting (CTR)
FinCEN Form 103 completed and filed by casinos to report cash transactions that are GREATER than $10,000 in a single gaming day
Review
MIL - Monetary Instrument Log


MTL - Multiple Transaction Log


CTR - Currency Transaction Report

Government Agencies Involved
Two Ways Casinos Are Effected
1) Requires financial institutions to keep records & file reports on CASH transactions of more than $10,000

Multiple Transaction Log (MTL)
Monetary Instrument Log (MIL)
Currency Transaction Report (CTR)

Two ways Casinos are Effected cont.
2) Report Suspicious Activity that might signify money laundering, tax evasion, or other criminal activities.

Unusual Activity Report
- Team Members
Suspicious Activity Report (SAR)
- Compliance
Money Laundering Control Act of 1986
Imposing criminal liability on a person or financial institution that knowingly assists in the laundering of money

Establishment of Compliance program

Suspicious Activity Report (SAR) 1996
Information sharing begins
USA Patriot Act
Title III: International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001
Why comply?
Prevent Criminal Activity
Help assist in Protecting the US Financial Systems
To avoid significant fines and penalties for you and the Casino
Reporting Day (Gaming Day)
24 hour time period between 5 am and 4:59 am

Employees will not discuss the "reporting day" with Patrons for purpose of Title 31 reporting

Is illegal to coach patrons in any way to AVOID or EVADE the reporting process
What's Cash?
Types of Cheque/Chips
Cash-In Transactions
When the casino RECEIVES cash from a patron
Cash-Out Transactions
When the casino GIVES cash to a patron
MIL's
Document to record Single Transactions of $3,000 or more involving negotiable instruments
MTL's
Record multiple transactions for patron(s)

$3,000 is BHCR's recording threshold

Each patron must have their own MTL

When to generate....
Anytime a team member
has knowledge
of any currency transaction in excess of $10,000 in ONE gaming day
How to Answer CTR Related Questions?
"It is a Federal Requirement to request identification for all cash transactions over the Federal threshold. All casinos follow this procedure."

If a problem should arise, contact your Supervisor/Manager/Director.
Department Forms
Table Games
MTL

Casino Cage
MIL
MTL

Compliance
CTR
FinCEN - Financial Crimes Enforcement Network


IRS - Internal Revenue Service
Bank Secrecy Act Anti-Money Laundering (BSA/AML)
Currency Transaction Reporting Training

This is Cash:
Important
Agent
An individual conducting transactions on behalf of another individual
Shared Wallet
Two or more individuals conducting gaming activities using the same funds as if they were one individual
This is NOT Cash:
Currency
Dollars & Coins
Change
and other "nickname" for money
Chips
Tickets
Checks
E-Checks
Credit Advance
Value
Table Games: Redeemed for cash at the Cage
Ex: Blackjack Chips
Negotiable gaming chip that has a specified value
Non-Value
Roulette chips or tournament chips
Roulette table sets value of chips
Redeemed at roulette table for value chips
Tournament chips can NOT be redeemed at the Cage
TITOs
Bar coded slip of paper printed out by a Slot machine
Can be redeemed for cash OR inserted for play into other Slot machines
Buying Casino Chips
Front Money or Safekeeping Deposits
Exchanging Cash for Casino Checks
BHCR Does Not Utilize
Payments on credit, including casino markers
Cash bets
Cash from wire transfers
Exchanging cash, including foreign currency exchange
Exchanging casino chips or TITOS for cash
not including slot jackpots
Withdrawals of deposits
front money or safekeeping
BHCR Does Not Utilize
Credit Advances, including casino markers
Payments on bets
Cashing of checks, money orders, travelers checks, etc.
Exchanging cash, including foreign currency exchange
Payment for travel & complimentary expenses
Rusty comes up to the Blackjack Table and buys in for $500 in chips. As the evening progresses he buys a few more times for $700 and $300 in cash.
Is Rusty's transaction Cash-In, Cash-Out or both?
Cash-In:
Buying chips, $1,500 CASH IN
Billy comes up to the Cage and cashes a check for $2,000. He then proceeds to the Blackjack Table to play. At the end of his evening, he comes up to the Cage with a handful of chips with a value of $700 wanting to exchange the chips for cash.
Is Billy's transaction Cash-In, Cash-Out, or both?
Missy and her husband Bob go up to Cage Window 2 to start their evening of fun at the Casino. Missy writes a personal check and receives $900 in Cash. By the end of the evening, Bob exchanges several TITO's with a value of $852.35 for cash.
Is Missy's transaction Cash-In, Cash-Out, or Both?
CASH OUT
Personal Check for $900 in Cash
Is Bob's transaction Cash-In, Cash-Out, or Both?
CASH-OUT
TITO's cashed out for $852.35
Sue comes up to the Cage with $1,000 worth of 20's and wants to have them exchanged for $100 bills. She then proceeds to play Poker. After winning big in the Poker Room she returns to the Cage with $2,000 in chips of her winnings. She gives the Cashier her chips and requests a casino check for her winnings.
Is Sue's exchange of bills Cash-In, Cash-Out, or both?
Is Sue's chip redemption Cash-In, Cash-Out, or both?
Both
Exchange of bills
NEITHER!
She didn't take Cash

MUST INCLUDE:
Patron's name, address, and account #
Type of instrument used & issuer
The amount, date & time of transaction
Employee signature & last 4 digits of KRGC #
Includes:
Amount
Location
Time
Type of Transaction
Detailed description of the patron
Making Corrections:
Cross out the error with a single line
Enter the CORRECT figure
Sign with initials and KRGC #
Jenny & Bill Jones are on their honeymoon. They come to Boot Hill Casino & Resort for the evening of dining & gamble.
Use the handout to fill out the MTL(s)
Following should be on file:
Valid Driver's License or form of ID
Social Security Number

Information is REQUIRED to complete the report
Acceptable forms of ID:
State issued Drivers License or Identification Card
Passport
U.S. Military ID
VISA
Slot jackpots are exempt from reporting
However, if a jackpot is paid with cash
from Safekeeping
then it is reportable.
CTR Verification of Taxpayer ID (SSN)
Copy of SSN Card
OR
Completed W-9
W-9 includes:
Patron's address
Social Security Number
Must be legible, confirm the numbers
Patron must sign
Refused ID/SSN
What to do:
Apologize to the patron for the inconvenience and explain to them the Federal requirements

If they still refuse:
Contact Supervisor
He/She will provide information to patron on requirements
Notify Security, Surveillance, & Compliance
Transaction is discontinued
E-mail and/or call Compliance
DO NOT BARGAIN WITH THEM
Penalties of Circumvention of CTR's
BHCR Repercussions
Fees & fines are levied
Sanctions are placed
Risk of loss of its operating license

Employee Repercussions
Criminal penalties up to $100,000 and/or imprisonment
Civil penalties up to $25,000
Loss of casino license
Loss of job
CTR Issues and Team Communication
$500
$2,000
$500
Cash-Out of $3,000
What form(s) is filled out?
MTL Filled Out
by Cage
$3,000
$4,500
$500
Cash-Out of $8,000
What form(s) is filled out?
MTL - Cage
MIL - Cage
Cash-In:
$1,500
Cash-Out:
$1,500
What forms are filled out?
NONE
Cash-In and Cash-Out Transactions are calculated
separately
Cash-In of $10,000
What forms are filled out?
Cage: MIL, MTL
Table Games: MTL

No CTR because it isn't over $10,000
A patron goes to the Cage and receives a $3,000 credit card advance taking it in cash. The patron then purchases $5,000 in chips with cash at Table Games. He later returns to the Cage and cashes out $8,000 redemption of chips.
What forms are filled out?
Table Games: MTL ($5,000)
Cage: MIL(3,000), MTL (3,000 + 8,000)
Compliance: CTR (11,000 = 3,000 + 8,000)
BHCR uses the term UNUSUAL ACTIVITY
BREAK!
Intended to facilitate the prevention, detection, and prosecution of international money laundering and the FINANCING OF TERRORISM
Both
Buying chips: $2,000 CASH IN
Exchange of chips: $700 CASH-OUT
Agents/Shared Wallets
Transactions made on behalf of another patron are marked with an *

State the NAME of the patron who made the transaction on behalf of another patron in the Agent/Shared Wallet Box
Write the Players Club #

If more than two patrons are involved, then use multiple, different *'s.
Check for patron at MTL level at the beginning of shift
Anticipate the ID/SSN requirements
Ask for ID or Players Club Card at earliest opportunity
Check KCMS for SSN
DO NOT
wait until the patron reaches CTR level

Communicate with team members about patrons near MTL or CTR level
$3,000 SINGLE Transactions
In-House form used by Cage
$3,000 Multiple Transactions
In-House form used by Cage & Table Games
Federal Form
Compliance completes using data from MTL's, MIL's, & KCMS Patron Records
Full transcript